Right Column
Mineral Resources Management Division - Rigs to Reefs Workshop
Jaime Kooser |
| ~ Submitted by the California Coastal Commission ~ |
Date: December 2, 1999
To: State Lands Commission
From: Peter Douglas, Executive Director
Re: Workshop on Conversion of Artificial Structures into Reefs
Due to a lengthy Coastal Commission agenda next week and other heavy workload demands, it is not possible for Commission staff to join you at your workshop. I hope I can adequately answer the questions we have been asked by your staff in this memorandum.
1. What are the Coastal Commission's regulatory responsibilities: The answer depends on the circumstances in each case. If an offshore artificial structure predates the Coastal Act and therefore was not subject to a coastal permit, shutting down the use and abandoning it in place could involve Commission regulatory review because it could be viewed as "development" pursuant to the Coastal Act (section 30106 PRC). Most physical development associated with any "abandonment", such as any demolition, would require a coastal permit. In our view, any proposal to partially demolish an offshore oil platform or other structure and leave it in place would require regulatory review and approval pursuant to the Coastal Act.
2. Commission science and scientific interest: The Commission has long had a strong interest in the science associated with artificial reefs to help answer questions such as whether these structures constitute good habitat with diverse and robust habitat values and function to actually increase the regional abundance of fish populations or where they are primarily fish-attractive devices. It is our opinion that the jury is still out on these questions. we are closely following and somewhat involved with the current scientific review of existing data to help answer these and other questions. The Commission is also directly involved with the establishment and monitoring of an artificial reef being created for the establishment of kelp forest habitat offshore Orange County. Application of extensive performance standards and careful evaluation of the extent to which they are met should give us substantial new information about the nature of artificial offshore structures and their habitat values.
3. The Coastal Commission's View of "rigs to reef" proposals: Although I cannot speak for the Commission since it has not yet formally addressed this issue, I can give you some preliminary views that reflect the staff's opinion in the matter. We have an "open mind" on the subject and are eagerly looking forward to the scientific information currently being gathered and evaluated that bears on the subject. As a starting principle, we are opposed to the concept that it is good environmental policy to abandon in the ocean the trappings and leavings of human activities after the primary purpose of the activity has been served. Having said that, we would have to examine the purpose for abandonment in place (e.g., its cheaper for the responsible party, for research and education, fishing, non-extractive recreational uses) and all potential environmental consequences of both abandonment in place and removal. Questions of liability and potential hazards also must be asked and answered. Given the precarious condition of many coastal fisheries in California, leaving a structure in place that could result in the accelerated depletion of fish stocks would not be something we would view favorable. On the other hand, we can see the merit in artificial structures providing valuable recreational opportunities not associated with the "take" of marine life (i.e., photography, living laboratories, underwater viewing and nature study).
If you would like additional information from the Coastal Commission, please let me know.